This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response to SC&A Findings on SEC-00223

Carborundum Company

Niagara Falls, NY

National Institute for Occupational 

Safety and Health 

June 8, 2016

Thomas P. Tomes 

National Institute for Occupational Safety and Health

Division of Compensation Analysis and Support 
NIOSH Response to SC&A Findings on SEC-00223

Page 2 of 5

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 1: 

NIOSH Failed to Prescribe a Methodology to Assess Doses to Skin of Hands and 

Forearms to X-Ray Diffraction (XRD) Apparatus

NIOSH Response: NIOSH reevaluated dose from XRD. See separate paper External 

Dose Assessment from X-Ray Diffraction at Carborundum Company, Niagara Falls, NY. 

That paper provides revised dose estimates and addresses issues identified by SC&A. 

NIOSH concludes that the exposure to a Rad Production Support personnel as specified 

in the DR methodology (10.8 R/yr shallow dose to skin and 115 R/yr to the hands and 

extremities) would be assigned to XRD technicians as a bounding estimate of dose.

Finding 2: 

NIOSH Failed to Address Thorium as a Possible Radiation Source

NIOSH Response: There is no information that suggests any thorium work that should 

be covered under EEOICPA, nor is there information indicating thorium work was 

performed during the AWE covered period. An interview with a former worker indicated

thorium fuel pellet work was done in 1955 (Ref ID 142193). NIOSH also has information 

from an interview with a claimant [redacted] that indicates thorium work in the mid1950s. Neither of those references provides details.

NIOSH has a reference that states Carborundum had two labs for studying radioactive 

material: there was one lab for uranium and thorium work, and another lab for plutonium

work (Ref ID 147253, p. 18). This is consistent with information provided by former 

workers during interviews.

NIOSH has a 1961 Carborundum document that lists government funded Carborundum 

research and development contracts from around 1950 through 1961 (Ref ID 147253, pp. 

27-28). None of the work listed includes or suggests thorium work; however, subcontract 

AT-34 with General Electric is listed from 1955 through 1958, but that reference 

indicates the scope of that contract was “classified” at that time. Other references 

indicate that contract was for the GE Aircraft Nuclear Propulsion (ANP) program that 

included work with uranium. It is possible the thorium work mentioned by the former 

worker may have been some experimental work under that subcontract. Records indicate 

some government-owned property was on-hand at Carborundum after termination of the 

GE subcontract and was subsequently transferred from the GE contract to 

Carborundum’s contract with the AEC in 1959, including some small quantities of 

uranium (<1 kg) (Ref ID 142022, pp. 235-260). 

Based on available information, it appears that non-covered uranium work was performed 

for several years prior to the 2nd AWE period, and some thorium work may have been 

done in 1955. Any alpha emitting radionuclides in the air from both AEC operations in 

1959 (and contamination from previous non-covered work) are reflected in the reported 
NIOSH Response to SC&A Findings on SEC-00223

Page 3 of 5

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

uranium (gross alpha) airborne radioactivity measurements. External dose from residual 

contamination would be insignificant in comparison to the doses assigned for the AEC 

contract work starting in 1959.

Finding 3: 

NIOSH Failed to Account for the Use of 90Sr in Thickness Gauges at Carborundum

NIOSH Response: The 1952 New York Times reference that SC&A discussed in the 

report indicates the sources were used in the “coated products division plant” to 

automatically control the thickness of sandpaper. As part of a reorganization and 

modernization program, Carborundum opened a new plant in 1947 for its Coated 

Abrasives Division, one of four divisions of the company at that time. The plant was 

located in Wheatfield, NY, in Niagara County, not at the Buffalo Avenue complex 

headquarters in Niagara Falls (Ref ID 73136, p. 67). One of the people interviewed for 

the Evaluation Report also said sandpaper was not made at the Buffalo Avenue Plant (Ref 

ID 142194).

NIOSH concludes the Sr-90 sources that were mostly likely at the Coated Abrasives 

Division Plant in Wheatfield, which is not a listed facility under EEOICPA. Therefore, 

assessment of dose from those sources is not applicable.

Finding 4: 

NIOSH Failed to Assign Doses from Medical X Rays During the First Operational 

Period

NIOSH Response: The example DR report reviewed by SC&A had a statement 

indicating “No medical X-ray doses were assessed.” The First Operational Period covers 

June 1943 through September 1943. The Evaluation Report (section 7.3.2) cites a 

reference that stated there were no health surveillance requirements for the 1943 work. 

SC&A mentioned a claimant indicated Carborundum required X-rays during that time, 

and dose should be assigned whether or not required by the AEC. NIOSH agrees that

dose from a single X-ray examination should be assigned in dose reconstructions for 

claimants with employment in 1943.

Finding 5: 

“Example DR” Failed to Assign Doses from Medical X Rays During the Second 

Operational Period

NIOSH Response: The example DR report reviewed by SC&A had a statement on the 

last line indicating “No medical X-ray doses were assessed.” To clarify, the example DR 

Report did not say they were not applicable; they were just not provided with the 

example calculations. NIOSH agrees that X-ray doses are applicable, as indicated in ER 

section 7.3.2. 
NIOSH Response to SC&A Findings on SEC-00223

Page 4 of 5

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 6: 

Inappropriate and Incorrect Use of FGR 12

NIOSH Response: NIOSH concurs with SC&A that the factors provided in TBD-6000 

provide for external dose from contamination and air immersion provide higher doses

than the factors in the example DR, which were derived from Federal Guidance Report 

Number 12. Therefore, the methods will be revised to use the TBD-6000 factors.

Finding 7: 

Dose calculations in “Example DR” Are Not Reproducible

NIOSH Response: Table 2 of the SC&A report shows doses estimated by NIOSH in 

the Example DR and doses estimated by SC&A for the same organs. It shows 

disagreement, some significant. The examples provided by NIOSH were not precise 

best estimates, and it appears the calculations by SC&A were also not precise

estimates. NIOSH employed some efficiency measures in the example DR, some of 

which resulted in marginally higher dose. Although NIOSH does not have the details 

of SC&A’s calculations, the descriptions indicate some efficiency measures were 

used to estimate dose. Separate responses for external and internal dose differences

are provided below. NIOSH can provide an updated example dose calculation 

showing details of the annual dose calculations. However, SC&A also had comments 

on interpretation of data to estimate both internal and external doses. Those 

comments, while not at the level of a finding, should be resolved before NIOSH 

provides an updated example calculation.

External Dose:

SC&A Table 2 shows NIOSH had external dose totals nominally 10% higher than 

SC&A calculated. As noted by SC&A, NIOSH used the higher Exposure (R) organ 

DCFs for calculating certain doses from uranium metal when the lower personal dose 

equivalent DCFs (Hp10) factors should have been used. NIOSH agrees with SC&A’s 

comment on the appropriate factors to use for exposure to uranium metal. NIOSH 

also employed some efficiency measures that resulted in some other marginal

overestimates.

Internal dose: 

Most notable in SC&A Table 2 is a large discrepancy in internal doses to the skin, 

liver, and kidneys. The total internal dose reported by NIOSH in the example DR is 

significantly higher than the total internal dose calculated by SC&A. SC&A’s total 

internal dose to the lung is only marginally different than the total provided by 

NIOSH, presumably within the accuracy of efficiency measures used to estimate 

dose.
NIOSH Response to SC&A Findings on SEC-00223

Page 5 of 5

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

The large discrepancy in the internal dose to the skin, liver, and kidneys is due to the 

NIOSH example DR incorrectly using solubility Type F as one of the possible 

solubility types for intakes from the 1943 uranium metal grinding work (Type S was 

correctly used for the lungs). NIOSH agrees with ER section 7.2.2.1 that only 

uranium solubility Types M and S should be considered for the metal grinding work 

in 1943, thus the reported internal doses in the example DR for the skin, liver, and 

kidneys are too high. NIOSH dose estimates for Type M are similar to those provided 

by SC&A, but there are small differences similar to those discussed below for the 

lung.

Regarding the relatively small difference in the lung dose calculations, some 

efficiency measures were used to estimate the doses. One such example is SC&A’s 

use of DCAL to calculate internal doses. DCAL doses are likely close, but different. 

(NOTE: SC&A commented that previous dose estimates using DCAL for an audit of 

case [redacted] were virtually identical to the dose estimate by NIOSH; however, the 

SC&A report for the audit of that case indicates SC&A used IMBA to check the 

NIOSH dose calculations, not DCAL). NIOSH also used some efficiency measures 

for certain intake components. NIOSH typically employs efficiency measures when 

they are deemed sufficient to determine the outcome of a claim. More accurate 

estimates are required when the outcome of dose reconstruction requires it (when 

overestimated or underestimated doses are not sufficient to determine 

compensability).